Thorncliffe Communications Ltd (“Thorncliffe”/”we”/”us”/”our”) take privacy and our use of your data seriously and acknowledge the importance of protecting any personal information – that is, any information from which a person can be identified, such as names, contact details and ID information (in this policy we call this “Personal Information”) that we hold.
Together, these three policies make up the Thorncliffe Privacy Policies.
We will ensure that your Personal Information is handled in accordance with the law. The relevant law here is: (i) the Data Protection Act 2018; (ii) the EU General Data Protection Regulation 2016; (iii) the Privacy and Electronic Communications (EC Directive) Regulations 2003; and (iv) all similar or related legislation relating to the processing of Personal Information and/or privacy applicable to Thorncliffe from time to time, as in force at the date of this Agreement, or as re-enacted, applied, amended, superseded, repealed or consolidated (together the “Data Protection Legislation”).
The “Data Controller” (as defined in the Data Protection Legislation) in respect of your Personal Information is Thorncliffe Communications Ltd, a limited company registered in England and Wales under number Z7642207
What personal information may Thorncliffe hold about you and how is it collected?
We may hold your personal information because:
- you supplied it to us;
- we learned it from someone else, either in the context of providing services to our clients or in the context of our business more generally;
- it is publicly available.
The personal information will generally consist of your name, business to business contact information and your job title, but may from time to time include further information.
If you apply for a job with us we will hold and process personal information relevant to recruitment which may include CVs, application forms, interview notes, results of pre-employment checks, references, DBS checks; information relating to your right to work (for example, passport information, visa details, immigration permissions, travel information); information relating to any reasonable adjustments for a disability. We collect this personal information either directly from you or from third parties including employment agencies, former employers, other referees, qualifications bodies, background check agencies or publicly available information.
Generally you have no obligation to provide us with your personal information, but if you do not provide information we ask for we may not be able to deal further with you (and in the recruitment context, we may not be able to progress your application).
What does Thorncliffe do with your personal information?
Thorncliffe will use your personal information:
- to provide our services;
- to run our business affairs, including internal record keeping;
- to carry out verification checks;
- to comply with our legal obligations, including reporting obligations;
- to send business or marketing communications which we think may be of interest (we will provide a simple mechanism to unsubscribe from such communications);
- to organise and hold marketing events in connection with the promotion of our business affairs.
We process recruitment information in order to ensure that we are recruiting employees who have the appropriate skills, qualification, experience and suitability for each role, and have the right to work in the UK. We may also process health information in order to comply with our duty to make reasonable adjustments.
Who does Thorncliffe share your personal information with?
We may disclose personal information to appropriate persons, where needed in order to enable us to achieve the objective of our processing of the data as described above. This includes to:
- credit reference or fraud and crime prevention agencies
- third party suppliers of services to Thorncliffe, in the course of their supply of such services, including service providers who assist our recruitment process
- regulatory bodies (as required by law).
Grounds for processing
The legal basis on which we hold your personal information is primarily for the purpose of pursuing our legitimate interests as a business which provides legal advice and services. In some instances we may rely on your express consent to use your personal information, but we will let you know (and give you the chance to withdraw consent) if we do. In some instances we may use your personal information in order to enable us to perform a contract which we have in place with you.
The legal basis for processing your personal information relating to recruitment is because it is necessary for our legitimate interests in operating our business efficiently or to comply with our legal obligations. Where we process recruitment information which falls within “special categories”, (which may include health information) or DBS check details, this is because it is necessary in connection with our employment law or regulatory rights, obligations and requirements.
Transfer outside the EEA
Where needed in order to enable us to achieve the objective of our processing the data as described above, we may transfer your personal information to third parties outside the European Economic Area. Where we do so we will only transfer your personal information to third parties outside the EEA if that third party (a) is situated in a country that has been confirmed by the European Commission to provide adequate protection to personal information, or (b) has agreed (by way of written contract) to provide all protections to your personal information as required by data protection legislation, or (c) if the transfer is otherwise permitted by law.
For how long does Thorncliffe keep your personal information?
We will keep your personal information for a period of time determined by our Data Retention Policy, which sets criteria for retention/destruction of data based on our business needs and regulatory requirements to which we are subject.
What rights do you have in respect of our holding your personal information?
Data protection legislation gives you the following rights in relation to the personal information we hold about you:
- you can ask what personal information we hold about you and be provided with a copy;
- if personal information is incorrect you can ask us to correct it;
- you can ask us to delete or cease processing of the personal information that we hold about you in certain circumstances, for example, where we no longer need that information;
- you can ask us to send you, or another organisation, certain types of personal information about you in a format that can be read by computer;
- you can withdraw your consent to our processing your personal information, where our processing is based on your consent;
- you can complain to the UK regulator, the Information Commissioner’s Office at www.ico.org.uk if you think that we aren’t complying with our obligations regarding your personal information.
Should you wish to exercise any of these rights, or if you have any queries or complaints in relation to how we use your personal information, please contact Deborah Paterson, who is the person responsible at Thorncliffe for managing how we look after personal information.